The FTC has not yet finally resolved its opinion on First party vs third party sites, according to my discussions with them. They say they don't have enough information--and we have now supplied them with details showing how the first and third party distinctions today are being obliterated by RTB, DSPs, ad data desks, etc. Most users do not know the data collection and online profiling/targeting practices of websites, including OPA members. OBA on a site is not really about recognizing a repeat customer--it's about a wide range of invisible and unaccountable engagement strategies that incorporate data analysis along with rich media, social media marketing, web optimization, "smart" ads, --even neuromarketing, etc. Rather than seeing DNT as a "kill switch," providing user control over a powerful process designed to influence their behavior and decision-making is a business practice that should benefit everyone.
Jeffrey Chester
Center for Digital Democracy
1621 Connecticut Ave, NW, Suite 550
Washington, DC 20009
www.democraticmedia.org
On Nov 30, 2011, at 3:43 PM, Chris Pedigo wrote:
> I appreciate Johnâ€™s note on the role of Consumer Watchdog to provide additional viewpoints for the W3C group to consider. I thought it would be helpful to add the viewpoint of the OPA on this issue. The following is a summary of comments we submitted earlier this year:
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> Our members include many of the Internetâ€™s most respected brands and they collectively reach an unduplicated audience of 172.5 million unique visitors, or 83% of the U.S. online population. Last year, OPA members invested approximately $750 million in the creation of high quality digital content, most of which they distribute free of charge.
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> Publishers know that their future ability to attract large consumer audiences to their digital properties will depend on consumersâ€™ trust. As a result, OPA members are acutely aware of the need to respect consumersâ€™ privacy interests while pursing their business objectives.
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> As noted earlier in a response on this issue, OPA shares the FTCâ€™s belief that collection and use of audience information for marketing purposes by companies that stand in a direct, first-party relationship with consumers have very different privacy implications than similar data collection and use by third parties (see http://www.ftc.gov/opa/2009/02/behavad.shtm ). In a direct first-party relationship, consumers are more likely to understand why they received tailored recommendations and are in a better position to raise concerns about use of information about them, or to exercise choice by taking their business elsewhere.
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> These considerations sharply distinguish publishersâ€™ first-party data collection practices from the third-party behavioral advertising practices that have been the focus of much of the policy debate surrounding online privacy. When behavioral advertising involves sharing data with ad networks or other third parties, as the FTC noted, the user â€œmay not understand why he has received ads from unknown marketers based on his activities at an assortment of previously visited websites. Moreover, he may not know whom to contact to register his concerns or how to avoid the practice.â€